Updated RSI Regulations (DOE)
On July 1, 2021, the Department of Education (DOE) released the final set of proposed regulations stemming from the 2019 Negotiated Rulemaking process (the Distance Education and Innovation Regulations). As part of these regulations, the definition of “distance education” in Chapter 34, §600.2 was updated, including specifically defining the critical terms: instructor, regular, and substantive.
These subsequent changes are reflected in the Memorandum of Understanding (see tabs below) between Foothill-De Anza Community College District and Foothill-De Anza Faculty Association.
In part, the agreement states that faculty teaching asynchronous online courses and hybrid courses with some asynchronous online hours must comply with the standards for Regular and Substantive Interaction (RSI) and accessibility. Therefore all faculty who plan to teach asynchronously must complete the training and certification.
Part 1 of the training includes sessions held two days: Wednesday (district Opening Day) AND Thursday (college Opening Day)
- Full-time (including Article 18) faculty members: Must complete training at both the district AND college Opening Day sessions. If you were not able to attend in person you will complete the asynchronous online course available after October 15, 2024.
- Full-time faculty members who are on approved leave for fall: May complete the asynchronous online RSI training course available after October 15, 2024.
- Full-time faculty members who have ADA accommodations (approved through the district Human Resources office): More details to follow.
- Part-time faculty members: Are encouraged to attend both days of Opening Day RSI training if possible, but may complete the asynchronous online RSI training course available after October 15, 2024.
- Article 19 faculty members: Are encouraged to attend both days of Opening Day RSI training if possible, but if you were not able to attend, you can complete the asynchronous online RSI training course available after October 15, 2024. In order to be paid for RSI training, you must revise your Article 19 paperwork to include any compensation that results from RSI training, and you need to ensure that total compensation for the year does not exceed your maximum allowable annual compensation.
- Faculty members who are not teaching online or hybrid but are required to do J1 evaluations (e.g. chairs, schedulers, tenure review committee members) that might contain an asynchronous online component must also complete RSI training.
Part 2 (Cohort or J1) of the training is also required and will be scheduled during the upcoming year. More details will be shared November 1, 2024.
Regular & Substantive Interaction refers to the federally mandated guidelines for instructor-led interaction with students in online and hybrid courses.
Let's break down the major components of expectations for all online and hybrid courses.
- Regular means scheduled and predictable communication with students consistently.
- Substantive means engaging students in meaningful discussion about course content.
- Interaction means instructor-initiated contact with an opportunity for students to respond.
RSI Training Requirements
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Agreement (MOU)
Please read the full Memorandum of Understanding between Foothill-De Anza Community College District and Foothill-De Anza Faculty Association for more information.
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Accreditation
Regular and Substantive Interaction is a practice that supports quality online teaching. Faculty discussions about RSI should be a central component of collegial sharing and professional learning. Because RSI is the key difference between online courses and correspondence courses, assessing RSI is a component of accreditation.
We want to continually improve our online teaching. The recent findings from the ACCJC, however, have added exigency to this work.
Please take a moment to read the Core Inquiries and Recommendations from the 2024 Accreditation Team.
ACCJC’s Policy on Distance and Correspondence Education.
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Training Requirements
The Regular and Substantive Interaction (RSI) certification consists of two parts, described below.
Assignment Guidelines
- To be assigned an asynchronous online course or a hybrid course with asynchronous hours in Spring 2025, faculty must complete Part I of training by the end of Fall 2024.
- To be assigned an asynchronous online or hybrid course in Fall 2025, faculty must complete both Part I and Part II of the RSI certification process by the end of Winter 2025.
- Scheduling of online or hybrid courses in Winter 2026 or beyond requires completion of both Part I and Part II by the time of scheduling for that quarter.
Part I
Coursework/Training Option
Credit or Compensation
A. Complete the RSI training course offered by FHDA online learning offices on Opening Days in Fall 2024 (4 hours on Sept 18, 2 hours on Sept 19)
Full-time faculty attend as part of opening day.
Part-Time Faculty attending receive normal pay for attendance ($150/day)
B. Complete the Asynchronous Training Option (Availalbe after 10/15/24
Full-Time faculty on approved leave & Part-Time faculty and Article 19 faculty unable to attend Opening Days are paid $300.
C. Submit an application for equivalency showing coursework or training from an accredited institution or @ONE. Coursework or training must have outcomes aligned with FHDA RSI training and faculty must provide proof of completion.
Granting of equivalency is not automatic. It is only granted by the campus Online Learning Office after being reviewed using same rubric that will be used to verify outcomes from in-house RSI training. PGA can be granted for coursework during FHDA employment if it has not already been used for placement.
Part II
Certification/Verification Options
Credit or Compensation
A. Participate in a one quarter cohort discussion group facilitated by online learning. Faculty member will share course RSI and accessibility features, and work with campus instructional designers and colleagues to ensure the course meets standards.
Cohort model requires certification by a representative of the Online Learning Office utilizing a rubric.
Faculty choose to earn either 2 Units of PGA or $500
B. Have an administrative evaluation of an asynchronous (J1.B) or hybrid (J1.C) course by an administrator trained on RSI. Must receive MT ratings as related to RSI and accessibility.
Administrators/faculty must attend RSI training prior to performing a J1.B or J1.C evaluation
No compensation for this option
NOTE
Completion of the required RSI training and certification will be tracked and coordinated by the Office of Online Education at De Anza.
If a faculty member requests Option B in a timely fashion, and the J1 is not completed in a timely fashion through no fault of the faculty member, the faculty member will not be denied an online teaching assignment in subsequent quarters.
De Anza's RSI Training Equivalency
We wanted to share the equivalency form with you for Part One of the RSI (Regular and Substantive Interaction) training. In accordance with the MOU on Regular and Substantive Interaction, “Granting of equivalency is not automatic. It is only granted by the campus Online Learning Center after being reviewed using the same rubric that will be used to verify outcomes from in-house RSI training.”
The Online Education Center will review the courses submitted for equivalency (completed after January 2022( to determine if they meet the learning outcomes of the Part One RSI training which include:
- Define Regular and Substantive Interaction in the context of your course
- Identify regular interaction that occurs in your course
- Identify key points in your course where substantive interaction is critical to student success
- Revise your syllabus and orientation to provide clear information to students on when and where regular and substantive interaction will occur in your course
- Create an internal communication plan that maps out when, where, and how you'll provide regular and substantive interaction in your online course
Missing or partial completion of the above learning outcomes will result in the course not meeting equivalency and requiring the instructor to complete the Opening Day RSI training or the online course during Fall Quarter. Due to state updates regarding RSI in online courses, we are also only considering courses completed from January 2022 and onward.
The Online Education Center recommends all faculty interested or currently teaching an asynchronous or hybrid course to attend the Opening Day RSI training or complete the asynchronous online course even if prior training has been completed. We are working hard to ensure the training is meaningful and will benefit all instructors.
Equivalency Application Form
To request equivalency, please submit an equivalency application form.
If you have any questions, please email nocitograbriela@fhda.edu
In addition, De Anza College adopted this Administrative Procedure AP 4105 Chapter 4 Distance and Correspondence Education In February 2024.
Resources
- Regular and Substantive Interaction Refresh (Most Current Updates/WCET 2021)
- Regular and Substantive Interaction: Background, Concerns, and Guiding Principles (PDF) Department of Higher Education
NEW RESOURCE
2024-25 Strategic Initiative: Distance Education Rubric
ACCJC recognizes that identifying and facilitating quality instruction in distance education, promoting equitable student outcomes in the modality, increasing clarity of ACCJC and federal expectations for institutions undergoing evaluation, and providing a consistent and objective approach for peer reviewers evaluating institutions are essential to ACCJC’s ongoing federal recognition and value as an accreditor.